[2023] KECA 1366 (KLR)

[2023] KECA 1366 (KLR)

The Court of Appeal held that the trial court erred by failing to consider the period the appellant spent in custody during the trial, as mandated by section 333(2) of the Criminal Procedure Code. Both parties agreed that the law requires the period spent in remand to be deducted from the total sentence imposed. The...

Source-derived case information.

Citation
[2023] KECA 1366 (KLR)
Parties
Appellant: Domnic Omondi Onyango; Respondent: Republic
Court
Court of Appeal
Court Station
Court of Appeal at Kisumu
Jurisdiction
Kenya
Case Number
Criminal Appeal 232 of 2018
Procedural Posture
Criminal Appeal / Appeal Against Sentence
Outcome
Appeal allowed; sentence computation clarified.
Judges
HM Okwengu, HA Omondi, JM Ngugi
Legal Topics
Sentencing Principles, Time Spent in Custody, Murder Offence
Source Language
en
Criminal Law Sentencing Principles Time Spent in Custody Murder Offence

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Parties

Domnic Omondi Onyango

Appellant

Republic

Respondent

Procedural Posture

Criminal Appeal / Appeal Against Sentence

  1. 1 Whether the trial court erred by failing to consider the period the appellant spent in custody during the trial when computing the sentence.
  2. 2 Whether section 333(2) of the Criminal Procedure Code mandates deduction of pre-sentence custody from the total sentence.

Ratio Decidendi

The Court of Appeal held that the trial court erred by failing to consider the period the appellant spent in custody during the trial, as mandated by section 333(2) of the Criminal Procedure Code. Both parties agreed that the law requires the period spent in remand to be deducted from the total sentence imposed. The appellate court therefore allowed the appeal and ordered that the 20-year sentence be computed from the date the appellant was first remanded in custody, ensuring compliance with statutory and policy requirements on sentencing.

Court Disposition

Appeal allowed; sentence computation clarified.

Orders

  • The 2 years spent in custody during trial to be factored in the computation of the 20-year prison sentence imposed on the appellant.
  • The 20-year sentence shall be computed to commence on 16th January, 2016, being the date the appellant was first arraigned in court and remanded in custody.